Coleman factors (Louisiana) · Go Syfert
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Coleman factors in Louisiana

35 Louisiana opinions name it 2 courts 1982–2026 11 in the last five years

The cases below were cited by Louisiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Coleman v. Denogreen
la · 2002 · cited in 8 Louisiana opinions naming this issue, 2002–2026
2 sentences

2026In Coleman, the supreme court held that, although EMTALA claims and medical malpractice claims often overlap, “Coleman’s claim of ‘dumping’— improper transfer—is one of malpractice governed by the MMA.” Id. at 315 .

2021Coleman factors In Coleman v. Deno, 01-1517 (La. 1/25/02), 813 So.2d 303, 315-316 , the Louisiana Supreme Court identified the following factors to be considered when 3 determining whether the conduct of a qualified health care provider constitutes “malpractice” as defined under the LMMA: [1] whether the particular wrong is ‘treatment related’ or caused by a dereliction of professional skill, [2] whether the wrong requires expert medical evidence to determine whether the appropriate standard of care was breached, [3] whether the pertinent act or omission involved assessment of the patient's co

18
Blevins v. Hamilton Medical Center, Inc.green
la · 2007 · cited in 4 Louisiana opinions naming this issue, 2011–2025
2 sentences

2025Ctr., Inc., 07-127 (La. 6/29/07), 959 So. 2d 440 ; Coleman, supra. Thus, we find the district court did not err in analyzing the record under the Coleman factors to determine whether plaintiff’s allegations sound in medical malpractice or general negligence. 10 In Billeaudeau, supra, the plaintiffs filed a lawsuit alleging, inter alia, their daughter’s injuries were caused by the hospital’s failure to properly credential an emergency room physician, who was employed as an independent contractor.

2012Applying the Coleman factors, the supreme court concluded that these complaints alleged general negligence, “as the wrongs alleged are not integral to the rendering of care and treatment by the health care provider to the patient in this case.” Blevins, 959 So.2d at 447 .

14
Williamson v. HOSPITAL SERVICE OF JEFFERSONgreen
la · 2004 · cited in 3 Louisiana opinions naming this issue, 2007–2023
2 sentences

2023Id. at 786-787.

2023Id. at 786-787.

13
Watson v. Woldenberg Village, Inc.green
lactapp · 2016 · cited in 2 Louisiana opinions naming this issue, 2023–2023
2 sentences

2023Whether the injury would have occurred if the patient had not sought treatment This Court has found this factor “inapplicable … in a nursing home context” where “the injury occurred not during the course of treatment delivery, but during [plaintiff’s] custodial care in the home.” Watson, 16-0159, p. 10, 203 So.3d at 324 .

2023Whether the injury would have occurred if the patient had not sought treatment This Court has found this factor “inapplicable … in a nursing home context” where “the injury occurred not during the course of treatment delivery, but during [plaintiff’s] custodial care in the home.” Watson, 16-0159, p. 10, 203 So.3d at 324 .

12
Andrews v. Our Lady of the Lake Ascension Community Hospital, Inc.green
lactapp · 2014 · cited in 1 Louisiana opinions naming this issue, 2023–2023
2 sentences

2023See Andrews, 142 So. 3d at 39 n.3. 12 administered to Mrs. Villanueva, as a result of the treatment she received at AVALA. " Malpractice" as set forth in La.

2023See Andrews, 142 So. 3d at 39 n.3. 12 administered to Mrs. Villanueva, as a result of the treatment she received at AVALA. " Malpractice" as set forth in La.

11
Price v. City of Bossier Citygreen
la · 1997 · cited in 1 Louisiana opinions naming this issue, 2011–2011
2 sentences

2011See Blevins, 959 So.2d 440 (analyzing the Coleman factors and finding that certain claims for injuries from an improperly secured hospital bed fell under general tort law and not medical malpractice, in part, because they did not arise in the context of a physician/patient relationship or within the scope of activities the hospital is licensed to perform); Price v. City of Bossier City, 96-2408 (La.5/20/97), 693 So.2d 1169, 1173 (an employer-mandated drug screen given to an employee who was treated for a non-drug related work injury was not given in the course of medical treatment as the emplo

2011See Blevins, 959 So.2d 440 (analyzing the Coleman factors and finding that certain claims for injuries from an improperly secured hospital bed fell under general tort law and not medical malpractice, in part, because they did not arise in the context of a physician/patient relationship or within the scope of activities the hospital is licensed to perform); Price v. City of Bossier City, 96-2408 (La.5/20/97), 693 So.2d 1169, 1173 (an employer-mandated drug screen given to an employee who was treated for a non-drug related work injury was not given in the course of medical treatment as the emplo

11
McLemore v. WESTWOOD MANOR NURS. AND REHAB.green
lactapp · 2003 · cited in 1 Louisiana opinions naming this issue, 2011–2011
2 sentences

2011See McLemore v. Westwood Manor Nursing & Rehabilitation, L.L.C., 37,450 (La.App. 2 Cir. 8/20/03), 852 So.2d 1170 (After a nursing home resident was allegedly dropped by staff and then was not treated for injuries sustained as a result of the fall, the claimant filed suit.

2011See McLemore v. Westwood Manor Nursing & Rehabilitation, L.L.C., 37,450 (La.App. 2 Cir. 8/20/03), 852 So.2d 1170 (After a nursing home resident was allegedly dropped by staff and then was not treated for injuries sustained as a result of the fall, the claimant filed suit.

11
Quinney v. Summit of Alexandriagreen
lactapp · 2005 · cited in 1 Louisiana opinions naming this issue, 2006–2006
2 sentences

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (27)

CaseCitedYears
LaCoste v. Pendleton Methodist Hosp. green
la · 2007
2 sentences

2016In LaCoste , the Court recognized, however, that despite the necessity of the patient entering the facility, “many claims of medical malpractice resulting from omissions might not qualify as medical malpractice if this factor were applied singly and without relation to the other Coleman factors, because an omission, such as a failure to diagnose, ostensibly leaves a patient in the same position as she would have been in had she never sought treatment in the first place.” Id.

2016In LaCoste , the Court recognized, however, that despite the necessity of the patient entering the facility, “many claims of medical malpractice resulting from omissions might not qualify as medical malpractice if this factor were applied singly and without relation to the other Coleman factors, because an omission, such as a failure to diagnose, ostensibly leaves a patient in the same position as she would have been in had she never sought treatment in the first place.” Id.

42010–2016
Brandi Billeaudeau, Veronica Billeaudeau, and Joseph Billeaudeau v. Opelousas General Hospital Authority, Dr. Kondilo Skirlis-Zavala, and the Shumacher Group of Louisiana, Inc. green
la · 2016
2 sentences

2018In its application of the Coleman factors, the Billeaudeau court noted that whether a particular wrong should be considered inherently "treatment-related" is a factor that can be artfully argued either way, see Bonilla, 210 So.3d at 550 (citing on Billeaudeau, 218 So.3d at 523 ), but ultimately concluded that the decision to hire a physician in and of itself is administrative and does not directly relate to the treatment of any given patient or involve a dereliction of professional skill.

2018In its application of the Coleman factors, the Billeaudeau court noted that whether a particular wrong should be considered inherently "treatment-related" is a factor that can be artfully argued either way, see Bonilla, 210 So.3d at 550 (citing on Billeaudeau, 218 So.3d at 523 ), but ultimately concluded that the decision to hire a physician in and of itself is administrative and does not directly relate to the treatment of any given patient or involve a dereliction of professional skill.

32018–2025
Bonilla v. Jefferson Parish Hospital Service District 2 green
lactapp · 2016
2 sentences

2018In its application of the Coleman factors, the Billeaudeau court noted that whether a particular wrong should be considered inherently "treatment-related" is a factor that can be artfully argued either way, see Bonilla, 210 So.3d at 550 (citing on Billeaudeau, 218 So.3d at 523 ), but ultimately concluded that the decision to hire a physician in and of itself is administrative and does not directly relate to the treatment of any given patient or involve a dereliction of professional skill.

2018In its application of the Coleman factors, the Billeaudeau court noted that whether a particular wrong should be considered inherently "treatment-related" is a factor that can be artfully argued either way, see Bonilla, 210 So.3d at 550 (citing on Billeaudeau, 218 So.3d at 523 ), but ultimately concluded that the decision to hire a physician in and of itself is administrative and does not directly relate to the treatment of any given patient or involve a dereliction of professional skill.

32018–2021
Richard v. Louisiana Extended Care Centers green
la · 2003
2 sentences

2010Richard, 835 So.2d at 469 .

2010Richard, 835 So.2d at 469 .

32003–2010
Campbell v. Nexion Health at Claiborne, Inc. neutral
lactapp · 2014
2 sentences

2024Id.

2024Id.

12024–2024
Plaisance v. Our Lady of Lourdes Regional Medical Center, Inc. neutral
lactapp · 2010
2 sentences

2016In Plaisance v. Our Lady of Lourdes Regional Medical Center, Inc., 10-348 (La.App. 3 Cir. 10/6/10) , 47 So.3d 17 , writ denied, 10-2520 (La.1/14/11), 52 So.3d 904 , this court engaged in an exhaustive examination of each of the Coleman factors to determine whether a claim for “negligent credentialing”' constituted a malpractice claim.

2016In Plaisance v. Our Lady of Lourdes Regional Medical Center, Inc., 10-348 (La.App. 3 Cir. 10/6/10) , 47 So.3d 17 , writ denied, 10-2520 (La.1/14/11), 52 So.3d 904 , this court engaged in an exhaustive examination of each of the Coleman factors to determine whether a claim for “negligent credentialing”' constituted a malpractice claim.

12016–2016
Lyncher v. Design Engineering, Inc. neutral
la · 2011
2 sentences

2016In Plaisance v. Our Lady of Lourdes Regional Medical Center, Inc., 10-348 (La.App. 3 Cir. 10/6/10) , 47 So.3d 17 , writ denied, 10-2520 (La.1/14/11), 52 So.3d 904 , this court engaged in an exhaustive examination of each of the Coleman factors to determine whether a claim for “negligent credentialing”' constituted a malpractice claim.

2016In Plaisance v. Our Lady of Lourdes Regional Medical Center, Inc., 10-348 (La.App. 3 Cir. 10/6/10) , 47 So.3d 17 , writ denied, 10-2520 (La.1/14/11), 52 So.3d 904 , this court engaged in an exhaustive examination of each of the Coleman factors to determine whether a claim for “negligent credentialing”' constituted a malpractice claim.

12016–2016
Billeaudeau v. Opelousas General Hospital Authority neutral
lactapp · 2016
2 sentences

2016App. 3 Cir. 4/6/16), 189 So.3d 561 . 7 While its analysis of the Coleman factors differed slightly from that of the lower court, the Court of Appeal nevertheless found the claim for negligent credentialing was not a claim of malpractice under the LMMA under the Coleman framework.

2016App. 3 Cir. 4/6/16), 189 So.3d 561 . 7 While its analysis of the Coleman factors differed slightly from that of the lower court, the Court of Appeal nevertheless found the claim for negligent credentialing was not a claim of malpractice under the LMMA under the Coleman framework.

12016–2016
Riley v. Maison Orleans II, Inc. green
lactapp · 2002
2 sentences

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

12012–2012
Clark v. Matthews neutral
la · 2002
2 sentences

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

12012–2012
Riley v. Maison Orleans II, Inc. neutral
la · 2002
2 sentences

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

2012Plaintiffs rely heavily on two Louisiana cases which apply the Coleman factors and conclude that similar injuries inflicted in a medical facility fall outside the scope of the LMMA. |7In Riley v. Maison Orleans II, Inc., 01-498 (La.App. 4 Cir. 9/25/02) , 829 So.2d 479, 496 , writs denied, 02-2653 (La.12/19/02), 833 So.2d 348 and 02-2646 (La.12/19/02), 833 So.2d 345 , a nursing home was held liable based on negligent supervision of staff for an attack by one resident on another under general tort principles.

12012–2012
Jordan v. STONEBRIDGE green
lactapp · 2003
1 sentence

2012Although we find that all Coleman factors have been satisfied in this case, Mrs. Matherne relies on this Court’s decision in Jordan v. Stonebridge, 03-0588 (La.App. 5 Cir. 11/25/03) , 862 So.2d 181 , to argue that her claim does not fall within the statutory definition of medical malpractice.

12012–2012
Delcambre v. Blood Systems, Inc. green
la · 2005
1 sentence

2011The supreme court examined who constitutes a patient in this context in Delcambre, 893 So.2d 23 .

12011–2011
Hernandez v. Diversified Healthcare-Abbeville, LLC green
lactapp · 2009
2 sentences

2010The defendant nursing home excepted on the grounds of prematurity, and after considering the Coleman factors, the appellate court found that the petition's "phraseology does not circumvent the requirement that the claim must be first submitted to the medical review panel." Id., 09-546 at p. 4, 24 So.3d at 287 .

2010The defendant nursing home excepted on the grounds of prematurity, and after considering the Coleman factors, the appellate court found that the petition's "phraseology does not circumvent the requirement that the claim must be first submitted to the medical review panel." Id., 09-546 at p. 4, 24 So.3d at 287 .

12010–2010
Jackson v. DeSOTO RETIREMENT AND REHAB. green
lactapp · 2005
2 sentences

2007Williamson, 888 So.2d at 789-790 . *453 Finally, in Jackson v. DeSoto Retirement and Rehabilitation Center Inc., 40,482 (La.App. 2nd Cir.12/14/05), 917 So.2d 727, 728-729 , a nursing home resident allegedly fell or was dropped, resulting in a fractured hip and complications which allegedly led to his death.

2007Williamson, 888 So.2d at 789-790 . *453 Finally, in Jackson v. DeSoto Retirement and Rehabilitation Center Inc., 40,482 (La.App. 2nd Cir.12/14/05), 917 So.2d 727, 728-729 , a nursing home resident allegedly fell or was dropped, resulting in a fractured hip and complications which allegedly led to his death.

12007–2007
McKnight v. D & W HEALTH SERVICES, INC. green
lactapp · 2003
2 sentences

2007Williamson, 888 So.2d at 790-791 . [5] We note that in a case factually distinguishable from the present case, this court in McKnight v. D & W Health Services, Inc., 2002-2552 (La.App. 1st Cir.11/7/03), 873 So.2d 18, 20 , addressed whether the death of a nursing home resident who was allowed to wander off the premises and died as a result of injury, heat exhaustion and exposure, constituted a claim for malpractice under the MMA.

2007Williamson, 888 So.2d at 790-791 . [5] We note that in a case factually distinguishable from the present case, this court in McKnight v. D & W Health Services, Inc., 2002-2552 (La.App. 1st Cir.11/7/03), 873 So.2d 18, 20 , addressed whether the death of a nursing home resident who was allowed to wander off the premises and died as a result of injury, heat exhaustion and exposure, constituted a claim for malpractice under the MMA.

12007–2007
Pender v. Natchitoches Parish Hosp. green
lactapp · 2003
2 sentences

2007Pender, 844 So.2d at 1110 .

2007Pender, 844 So.2d at 1110 .

12007–2007
Furlow v. Woodlawn Manor, Inc. green
lactapp · 2005
2 sentences

2006Accordingly, we will limit our analysis to whether the alleged acts of negligence in failing to timely clean and change Ms. Allen on a regular, timely basis constitute medical malpractice. [4] See Furlow, 39,485 at p. 6, 900 So.2d at 340 . *558 Applying the Coleman factors set forth above, we conclude, as have the Second and Third Circuits in addressing this precise issue, that the trial court erred in finding that the alleged acts of failing to timely clean and change Ms. Allen on a regular basis constitute medical malpractice and, thus, were subject to the requirements of the MMA.

2006Accordingly, we will limit our analysis to whether the alleged acts of negligence in failing to timely clean and change Ms. Allen on a regular, timely basis constitute medical malpractice. [4] See Furlow, 39,485 at p. 6, 900 So.2d at 340 . *558 Applying the Coleman factors set forth above, we conclude, as have the Second and Third Circuits in addressing this precise issue, that the trial court erred in finding that the alleged acts of failing to timely clean and change Ms. Allen on a regular basis constitute medical malpractice and, thus, were subject to the requirements of the MMA.

12006–2006
Burks v. Christus Health Monroe green
lactapp · 2005
2 sentences

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

12006–2006
Henry v. West Monroe Guest House, Inc. green
lactapp · 2005
2 sentences

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

12006–2006
Womack v. AUTUMN LEAVES NURS. & REHAB. CEN. neutral
lactapp · 2005
2 sentences

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

12006–2006
Rogers v. HICKORY MANOR NURSING & REHABIL. neutral
lactapp · 2005
2 sentences

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

2006See Quinney v. Summit of Alexandria, 2005-237, pp. 10-11 (La.App. 3rd Cir.6/1/05), 903 So.2d 1226, 1233-1234 ; Rogers v. Hickory Manor Nursing & Rehabilitation, L.L.C., 39,626, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1150, 1153-1154 ; Womack v. Autumn Leaves Nursing & Rehabilitation Center, L.L.C., 39,710, p. 5 (La.App. 2nd Cir.5/11/05), 902 So.2d 1280, 1283 ; Furlow , 39,485 at pp. 7-8, 900 So.2d at 340 ; Burks , 39,540 at pp. 5-6, 899 So.2d at 779 ; and Henry, 39,442, 895 So.2d at 683 .

12006–2006
Sewell v. Doctors Hosp. green
la · 1992
12002–2002
State v. Maduell green
la · 1976
11985–1985
State v. Williams green
la · 1976
11985–1985
Fid. & Dep. Co. of Md. v. Cloy Const. Co. green
lactapp · 1983
11984–1984
Breithaupt v. Sellers green
la · 1980
11982–1982

Statutes the citing opinions construe

LA § La. Rev. Stat. § 40:1231.1 (15) LA § La. Rev. Stat. § 1 (5) LA § La. Rev. Stat. § 40:2010.8 (5) LA § La. Rev. Stat. § 40:2010.9 (5) LA § La. Rev. Stat. § 40:1231.2 (3) LA § La. Rev. Stat. § 40:2009.2 (3) LA § La. Rev. Stat. § 40:2010.6 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

LA 35 (1982–2026) AK 24 (1980–2023) OH 23 (1971–2026) CA 20 (1965–2025) TX 16 (1969–2026) IL 11 (1972–2020) GA 11 (1981–2025) MS 11 (1985–2009) WI 9 (2002–2024) MO 8 (1918–2021) MT 6 (1979–2020) AL 6 (1976–2011) IN 6 (1990–2019) IA 5 (2016–2017) PA 5 (1968–2023) WA 5 (1980–2014) MI 4 (1971–2025) DE 4 (1977–2023) SC 4 (2011–2023) KS 4 (2003–2021) ME 3 (2018–2019) TN 3 (2012–2026) FL 3 (1993–2020) NE 3 (1981–2025) NJ 2 (1985–2020) MN 2 (2009–2009) DC 2 (1987–2019) UT 2 (2019–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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